PURSHOTTAM GOVINDJI HALAI vs SHREE B. M. DESAI, ADDITIONAL COLLECTOR OF BOMBAY & OTHERS

The Supreme Court held that Section 46(2) of the Indian Income-tax Act, 1922, and Section 13 of the Bombay Land Revenue Act, 1876, do not violate Articles 13(1), 14, or 21 of the Constitution. The Court found that the procedure established by law under Section 13 of the Bombay Act was valid and did not infringe upon fundamental rights. The argument that Section 46(2) grants arbitrary power to the Collector was rejected, affirming that it does not provide for alternative recovery methods but rather enhances the effectiveness of the existing procedure.